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Does anyone know where and how the public can provide their comments? I cannot find a link on the page. Bootstrapped startups with no outside investments wouldn't be eligible based on this criteria.

you are right and that was probably intentional. if not, there would be no way to determine if a startup is legitimate or not. attracting investment or funding seems to be the determining factor in this process.

What about using growth, revenue and profitability as a factor? Wouldn't that provide a similar data point to make the decision.

If you have growth and revenue, it should be easy to get investors to invest. By outsourcing their decision, the government doesn't have to understand how to benchmark growth or revenue in every kind of business.

Ok I found the link to submit comments if anyone is interested. From the publication PDF:

"You may submit comments, identified by DHS Docket No. USCIS-2015-0006, by any one of the following methods:"

Web: http://www.regulations.gov Email: uscisfrcomment@dhs.gov Mail: Department of Homeland Security, 20 Massachusetts Avenue, NW, Washington, DC 20529

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